Customs Proposes To Substantially Transform The Substantial Transformation Test
Client Alert | less than 1 min read | 08.08.08
By Notice of Proposed Rulemaking, 73 Fed. Reg. 43385 (July 25, 2008), Customs & Border Enforcement has proposed substituting, for many purposes including rulings under the Trade Agreements Act (TAA), a "tariff shift" approach for determining country of origin in lieu of the longstanding and subjective "case-by-case" approach to determining the place where "substantial transformation" occurred. Under the proposed rule, contractors selling products under the contracts subject to the TAA would have to reevaluate their products under the rigid, pre-established formulaic tariff shift analysis to ensure products with significant non-designated country content qualify for sale to the federal government.
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Client Alert | 4 min read | 12.08.25
California’s AB 2013 Requires Generative AI Data Disclosure by January 1, 2026
California continues its blistering pace in enacting artificial intelligence regulations. In 2024 alone, California enacted 18 AI-related bills seeking to regulate AI tools and increase transparency around AI data disclosure.
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
Client Alert | 21 min read | 12.04.25
Highlights: CMS’s Proposed Rule for Medicare Part C & D (CY 2027 NPRM)


